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Computer Graphics was formed after September 3, 1982.
Accordingly, the examination of Computer Graphics' 1982 taxable
year was required to be made, and was in fact made, pursuant to
the unified partnership audit and litigation procedures set forth
in sections 6221 through 6231.1 Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),
96 Stat. 324, 648.
Petitioner's name and address do not appear on the Schedule
K-1 that was filed with the partnership's return for 1982.
Further, there is no indication on the schedule that petitioner
had any interest in Computer Graphics. Petitioner never provided
any information to the Commissioner pursuant to section 6223(c)
or section 301.6223(c)-1T(b), Temporary Proced. and Admin. Regs.,
52 Fed. Reg. 6784 (Mar. 5, 1987) that she had any interest in
Computer Graphics.
The Partnership Proceeding
In January 1985, and pursuant to section 6223(a)(1),
respondent mailed Mr. Olson a notice of beginning of
administrative proceeding (NBAP) regarding the examination of
Computer Graphics' partnership return for 1982. The NBAP was
addressed to Mr. Olson and was mailed to the address set forth on
Schedule K-1 of the partnership return.
1 Unless otherwise indicated, all section, subchapter, and
chapter references in this Opinion are to the Internal Revenue
Code, as amended.
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